--- title: "CAMO, CAO and Part-145: Roles Compared · Avioverse" description: "Compare EASA CAMO, CAO and Part-145 responsibilities, approval limits, owner duties and the handover from maintenance planning to release and records." url: "https://avioverse.aero/guides/easa-camo-continuing-airworthiness-management-organisation" --- # CAMO, CAO and Part-145: Who Does What? Compare EASA CAMO, CAO and Part-145 responsibilities, approval limits, owner duties and the handover from maintenance planning to release and records. [Dionysis Kefalas](https://avioverse.aero/articles/author/dennis-kefalas) 12 Jun 2026 Updated 21 Oct 2026 7 min read For CAMO and Part-145 staff Part 5 of 12 in EASA Continuing Airworthiness Show parts Hide parts 1. 1 [Continuing Airworthiness: Part-M and Part-CAMO](https://avioverse.aero/guides/easa-continuing-airworthiness-explained) 2. 2 [Aircraft Maintenance Programme under Part-M](https://avioverse.aero/guides/easa-aircraft-maintenance-programme-amp) 3. 3 [EASA Reliability Programmes and Monitoring](https://avioverse.aero/guides/easa-reliability-programme-monitoring) 4. 4 [Airworthiness Reviews and the ARC](https://avioverse.aero/guides/easa-airworthiness-review-certificate-arc) 5. 5 CAMO, CAO and Part-145: Roles Compared 6. 6 [Part-M: Release to Service and Records](https://avioverse.aero/guides/easa-maintenance-release-to-service-records) 7. 7 [EASA Airworthiness Directives and AD Compliance](https://avioverse.aero/guides/easa-airworthiness-directives-ad-compliance) 8. 8 [LLP Back-to-Birth Records and M.A.305 Tracking](https://avioverse.aero/guides/aircraft-component-records-life-limited-parts) 9. 9 [Aircraft Reliability Programme, Step by Step](https://avioverse.aero/guides/aircraft-reliability-programme-step-by-step) 10. 10 [Service Bulletin Evaluation in a CAMO](https://avioverse.aero/guides/service-bulletin-evaluation-camo) 11. 11 [CAMO Staff Competence and Manpower Planning](https://avioverse.aero/guides/camo-staff-competence-assessment-manpower) 12. 12 [CAMO Subcontracting and Maintenance Contracts](https://avioverse.aero/guides/camo-subcontracting-maintenance-contract) Quotes checked on 8 Oct 2026 against 2 sources. Show sources Hide sources - EASA Easy Access Rules for Continuing Airworthiness — 2 Sep 2025 baseline - relevant provisions amended by Regulations (EU) 2025/111 and 2026/100 On this page ## CAMO, CAO and Part-145 at a glance A **continuing airworthiness management organisation (CAMO)** manages the programme and arrangements that keep an aircraft airworthy. A **Part-145 maintenance organisation** performs and releases maintenance. A **combined airworthiness organisation (CAO)** may hold management privileges, maintenance privileges or both, within a narrower aircraft scope. One business can hold more than one approval; its trading name does not tell you which privileges it holds. | Approval | Main role | Limits to check before assigning work | | ------------- | ------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | **Part-CAMO** | Develop and control the aircraft maintenance programme (AMP), including any applicable reliability programme; arrange and coordinate maintenance. | Aircraft and work must be within its certificate and continuing airworthiness management exposition (CAME). CAMO approval alone does not authorise maintenance release. CAMO.A.125 and CAMO.A.315. | | **Part-CAO** | Perform maintenance, manage continuing airworthiness, or hold both privileges, as approved. | Check the certificate and combined airworthiness exposition (CAE). CAO.A.010 normally limits scope to non-complex aircraft not on a licensed air carrier’s air operator certificate (AOC). Article 3(7) applies non-complex requirements to specified provisions, including CAO.A.010, for multi-turboprop aeroplanes at or below 5,700 kg maximum certificated take-off mass; the licensed-carrier restriction remains. CAO.A.020 and CAO.A.095. | | **Part-145** | Perform approved maintenance and issue a certificate of release to service (CRS). | Check aircraft/component ratings, work and location against the approval and maintenance organisation exposition (MOE). Appropriately authorised certifying staff issue the release under 145.A.50; it does not transfer all airworthiness duties. 145.A.75. | “Combined” does not guarantee that a CAO offers every service: [CAO.A.095 (full rule text)](https://avioverse.aero/regulations/easa/continuing-airworthiness/part-cao/section-a-organisation-requirements/cao-a-095) Privileges of the organisation > \[…] > > (e) A CAO may be approved for one or more privileges. Quoted word for word from Regulation (EU) No 1321/2014, amended by (EU) 2026/100, EAR baseline 2 Sep 2025; amendment applicable 7 August 2026. Read the [Part-CAO scope provision](https://www.easa.europa.eu/en/document-library/easy-access-rules/online-publications/easy-access-rules-continuing-airworthiness?erules-id=ERULES-1963177438-14350) alongside the [current privilege amendments](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32026R0100). CAO scope is not synonymous with Part-ML eligibility; the [continuing-airworthiness overview](https://avioverse.aero/guides/easa-continuing-airworthiness-explained) explains the wider framework. ## What remains with the owner or operator? M.A.201(a) and ML.A.201(a) start with owner responsibility: no flight unless the aircraft is airworthy, operational and emergency equipment meets the stated conditions, the airworthiness certificate is valid, and maintenance follows the AMP. Their leasing provisions transfer the specified responsibilities to the lessee when the registration document or lease meets the rule’s conditions. Operator-specific duties then depend on the operation. For a licensed air carrier, M.A.201(e) places responsibility on the operator, with CAMO approval normally part of its AOC and Part-145 maintenance performed under its own approval or a written contract. M.A.201(ea) allows at least two operators within a single air carrier business grouping to share a CAMO only under its conditions, including appropriate approval, a same-group CAMO, the required contract, its place of business and harmonised management systems. This is a defined [group arrangement under Regulation 2022/410](https://eur-lex.europa.eu/legal-content/EN/TXT/?toc=OJ%3AL%3A2022%3A084%3ATOC\&uri=uriserv%3AOJ.L_.2022.084.01.0020.01.ENG). For Part-ML, the [responsibility rule ML.A.201](https://www.easa.europa.eu/en/document-library/easy-access-rules/online-publications/easy-access-rules-continuing-airworthiness?erules-id=ERULES-1963177438-14270) makes a useful distinction. The commercial-training and other operational cases listed in paragraph (e) require CAMO/CAO management, through approval or contract, and approved maintenance. For aircraft outside those cases, paragraph (f) allows the owner to contract management or perform it. A contracted organisation assumes responsibility for properly performing those tasks; that does not erase the remaining duties in ML.A.201. Maintenance also has its own accountability: [M.A.201(c) (full rule text)](https://avioverse.aero/regulations/easa/continuing-airworthiness/part-m/section-a-technical-requirements/m-a-201-c) Responsibility for maintenance performed > (c) Any person or organisation performing maintenance shall be responsible for the tasks performed. Quoted word for word from Regulation (EU) No 1321/2014, Easy Access Rules for Continuing Airworthiness, 2 Sep 2025 revision. ## A practical handover from planning to records A useful handover makes the work, decisions and evidence traceable. The checks below are practical prompts, not prescribed form names. They illustrate a CAMO working with a Part-145 organisation; adapt them to the actual approvals and contracts. | Handover | Responsible activity | Evidence to check | | ---------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | | **Owner/operator → CAMO** | Define the management assignment under the applicable M.A.201 or ML.A.201 case. | Aircraft coverage, approval scope, required written contract and named contacts. Do not treat a maintenance order as the management contract. | | **CAMO → maintainer** | Arrange appropriate approved maintenance; order, supervise and coordinate it under CAMO.A.315(b) and (c). | Controlled AMP and applicable reliability inputs, ordered work, relevant data references, and agreed responsibilities. | | **Maintainer → airworthiness manager** | Bring new defects or incomplete work orders to the responsible person/organisation for agreement under 145.A.50(c). | Findings, proposed action and an explicit decision. Any release with incomplete ordered work must meet 145.A.50(e), including approved aircraft limitations and recording the incompletion in the CRS. | | **Maintainer → operator/customer** | Authorised certifying staff issue the CRS when the applicable release conditions are met; return the required records. | CRS copy plus associated detailed maintenance records needed to demonstrate M.A.305/ML.A.305 compliance: 145.A.55(a)(2). | | **Both organisations → their records systems** | Each fulfils its own retention duties: 145.A.55(a) and CAMO.A.220(a). | Confirm delivery, receipt and usable records. A shared portal does not by itself fulfil either organisation’s retention duty. | The CAMO’s coordination duty is explicit: [CAMO.A.315 (full rule text)](https://avioverse.aero/regulations/easa/continuing-airworthiness/part-camo/section-a-organisation-requirements/camo-a-315) Continuing airworthiness management > \[…] > > (b) For every aircraft managed, the organisation shall in particular: > > \[…] > > (6) order maintenance, supervise activities, and coordinate related decisions to ensure that any maintenance is carried out properly and is appropriately released for the determination of aircraft airworthiness. > > \[…] Quoted word for word from Regulation (EU) No 1321/2014, Easy Access Rules for Continuing Airworthiness, 2 Sep 2025 revision. The [maintenance-release rule](https://www.easa.europa.eu/en/document-library/easy-access-rules/online-publications/easy-access-rules-continuing-airworthiness?erules-id=ERULES-1963177438-268) and [record-return rule](https://www.easa.europa.eu/en/document-library/easy-access-rules/online-publications/easy-access-rules-continuing-airworthiness?erules-id=ERULES-1963177438-269) explain the receiving side. See the separate guides for [AMP control](https://avioverse.aero/guides/easa-aircraft-maintenance-programme-amp), [reliability monitoring](https://avioverse.aero/guides/easa-reliability-programme-monitoring) and [release and records](https://avioverse.aero/guides/easa-maintenance-release-to-service-records). **Example:** ExampleAir’s CAMO arranges a scheduled check at ExampleMRO. The CAMO coordinates the work against the AMP; ExampleMRO performs it within its Part-145 approval. When ExampleMRO finds an additional defect, it communicates the finding for an agreed action. Its authorised certifying staff issue the CRS when the release conditions are met, and the release and required supporting records return to the customer. The CAMO manages the continuing-airworthiness follow-through; its management role alone does not entitle its staff to sign the maintenance release. ## What should the management system and exposition show? CAMO.A.200 requires accountability, safety policy, hazard and risk management, competent people, documented processes and compliance monitoring, proportionate to the organisation’s size, activities and risks. CAMO.A.305 assigns the accountable manager responsibility for resources and nominated management, safety and compliance functions. The [Part-CAMO management-system requirements](https://www.easa.europa.eu/en/document-library/easy-access-rules/online-publications/easy-access-rules-continuing-airworthiness?erules-id=ERULES-1963177438-14324) provide the detailed framework. The CAME records scope, responsibilities and procedures; its initial issue requires authority approval under CAMO.A.300. A CAO has its CAE and its own CAO.A.100 quality-system requirements. A small CAO may replace the quality system with regular organisational reviews only with authority approval; in that case it cannot contract management tasks to other parties. When checking an arrangement, look for procedures that explain the actual handover, escalation and record custody. ### Why the CAME amendment form asks what it asks Use the CAME branch of Exposition amendment (no prior approval) when preparing a controlled change, beginning with a check of the route. Document identity, current and proposed revisions and changed chapters locate the management-system documentation addressed by CAMO.A.200(a)(5). The reason for the change and references to supporting material let the reviewers assess the affected processes and the relevant documentation under CAMO.A.130(b). The prior-approval question prevents the form’s title from deciding the route. CAMO.A.130(a) includes changes to certificate scope or approval terms, the specified nominated personnel and their reporting lines, and the procedure for changes not requiring prior approval. Point (b) also covers other applicable prior-approval requirements: apply before the change, provide the relevant documentation and implement only after formal authority approval. Point (c) requires other changes to be managed and notified under the procedure approved by the authority. An internal review cannot replace required authority approval. The process owner records the proposed change; the responsible manager reviews it, and the compliance monitoring manager records the route and notification evidence. Where prior approval is required, record the referral and obtain it before implementation. These are written follow-up responsibilities within the workspace. This explanation applies to the CAME under Part-CAMO; use the [MOE guide](https://avioverse.aero/guides/easa-part-145-maintenance-organisation-exposition) for the form’s Part-145 branch. For the detailed contracting arrangements behind the handover above, see [CAMO contracting and subcontracting](https://avioverse.aero/guides/camo-subcontracting-maintenance-contract). ## Does the approval include airworthiness reviews? Check this separately from maintenance and management. CAMO.A.125(e) and CAO.A.095(c) provide additional review privileges subject to approval and their conditions. A Part-145 organisation can perform reviews and issue an **airworthiness review certificate (ARC)** only when specifically approved under 145.A.75(f), for Part-ML aircraft, with its principal place of business in a Member State. Current ML.A.901(c)(3) requires this while performing the AMP’s 100-hour/annual inspection, under ML.A.903. It is not a general Part-145 privilege. The [2026/100 amendment](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32026R0100) supplies the current ML.A.901 text; the [ARC guide](https://avioverse.aero/guides/easa-airworthiness-review-certificate-arc) covers the review and extension rules. ## Sources and revision boundary This guide uses the **2025-09-02 EAR baseline** with relevant provisions amended by [Regulation 2025/111](https://eur-lex.europa.eu/eli/reg_impl/2025/111/oj/eng) and [Regulation 2026/100](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32026R0100). Their relevant amendments apply from **13 February 2026** and **7 August 2026**, respectively. EASA’s [September 2025 EAR publication](https://www.easa.europa.eu/en/document-library/easy-access-rules/easy-access-rules-continuing-airworthiness) expressly excludes 2025/111, so that publication alone is not the complete current text. ## Forms in this guide ### Organisation - Exposition amendment (no prior approval) Review a CAME or MOE amendment under the procedure for changes not requiring prior approval, and record its internal approval and authority notification. | Question | Answer type | Required | | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | --------------------------------------------------------------------------------------------------------------------------------- | -------- | | Exposition | Choice: CAME, MOE | Yes | | Exposition reference | Short answer | Yes | | Current issue, revision and date | Short answer | Yes | | Proposed issue and revision | Short answer | Yes | | Changes, by part or chapter | Long answer | Yes | | Basis for the change | Long answer | Yes | | Prior authority approval requirement Check CAMO.A.130(a)–(b) or 145.A.85(a)–(b), including any other applicable prior-approval requirements. A Yes answer requires authority approval before implementation. | Choice: No – managed under our procedure for changes not requiring prior approval, Yes – apply to the competent authority instead | Yes | Once a response is submitted, the form opens these follow-up steps: - Change review - Compliance approval Educational content, not regulatory compliance advice. Verify against the current regulation text before relying on it. ## In this series ## Frequently asked questions ### Does a CAMO carry out maintenance? CAMO approval gives continuing-airworthiness management privileges. To perform and release maintenance, the organisation needs the applicable maintenance approval as well. CAMO.A.315(c) addresses maintenance contracts where the CAMO does not hold that approval. ### Does a CAO always provide both maintenance and management? No. CAO.A.095(e) permits one or more privileges. Check the actual approval certificate and combined airworthiness exposition for maintenance, management and any additional review privileges, together with their aircraft and work limits. ### Is a CAO restricted to Part-ML aircraft? No. CAO.A.010 is not a Part-ML-only boundary. It covers non-complex aircraft outside a licensed air carrier’s AOC, subject to approval scope. Article 3(7) also provides specific treatment for multi-turboprop aeroplanes at or below 5,700 kg maximum certificated take-off mass. ### Can a Part-145 organisation issue an ARC? Only with specific approval under 145.A.75(f), for Part-ML aircraft and with its principal place of business in a Member State. ML.A.901(c)(3) requires the review and ARC issue while performing the AMP’s 100-hour/annual inspection, under ML.A.903. ### Does a CAMO contract transfer every owner responsibility? No. For example, ML.A.201(f) places responsibility for properly performing contracted management tasks on the CAMO or CAO. The applicable owner or operator still has duties under ML.A.201. Lease provisions and the type of operation affect who holds those duties. ### Can a private aircraft owner manage airworthiness without a CAMO? Some can. ML.A.201(f) permits owner management for aircraft outside ML.A.201(e); M.A.201(i) provides separate Part-M cases. Check the aircraft and operation first: a private ownership label alone does not establish eligibility. ### Are the CAME, CAE and MOE the same document? They serve different approvals: continuing airworthiness management exposition for a CAMO, combined airworthiness exposition for a CAO, and maintenance organisation exposition for Part-145. An organisation holding several approvals must meet each applicable set of requirements. ## Related - [EASA Continuing Airworthiness Explained: Part-M, Part-CAMO and Who Keeps an Aircraft Airworthy Guide · 16 min](https://avioverse.aero/guides/easa-continuing-airworthiness-explained) - [The Aircraft Maintenance Programme (AMP) under Part-M Guide · 10 min](https://avioverse.aero/guides/easa-aircraft-maintenance-programme-amp) - [Reliability Programmes and Reliability Monitoring Guide · 5 min](https://avioverse.aero/guides/easa-reliability-programme-monitoring) - [Airworthiness Reviews and the ARC Guide · 12 min](https://avioverse.aero/guides/easa-airworthiness-review-certificate-arc) - [Maintenance, Release to Service and Continuing-Airworthiness Records Guide · 11 min](https://avioverse.aero/guides/easa-maintenance-release-to-service-records) - [EASA Airworthiness Directives: AD Compliance Explained Guide · 21 min](https://avioverse.aero/guides/easa-airworthiness-directives-ad-compliance) - [LLP Back-to-Birth Records and Component Tracking (M.A.305) Guide · 17 min](https://avioverse.aero/guides/aircraft-component-records-life-limited-parts) - [The maintenance organisation exposition (MOE) Guide · 6 min](https://avioverse.aero/guides/easa-part-145-maintenance-organisation-exposition) - [CAMO contracting and subcontracting Guide · 10 min](https://avioverse.aero/guides/camo-subcontracting-maintenance-contract) Written by Dionysis Kefalas. Retired Hellenic Air Force Captain and founder of Avioverse. [About the author](https://avioverse.aero/articles/author/dennis-kefalas) [Or request early access →](https://avioverse.aero/register?redirect=https%3A%2F%2Fapp.avioverse.aero%2Faudits) Share [LinkedIn](https://www.linkedin.com/sharing/share-offsite/?url=https%3A%2F%2Favioverse.aero%2Fguides%2Feasa-camo-continuing-airworthiness-management-organisation)[X](https://twitter.com/intent/tweet?url=https%3A%2F%2Favioverse.aero%2Fguides%2Feasa-camo-continuing-airworthiness-management-organisation\&text=CAMO%2C%20CAO%20and%20Part-145%3A%20Roles%20Compared)